Last Updated: April 1, 2023
CUBenefits LLC

This Privacy Policy (or “Policy”) explains how Credit Union Benefits  (“Credit Union Benefits,” “Company,” “we,” or “us”) collects, uses, stores, and protects your information whenever you use www.CreditUnionBenefits.org (or “Services”).

Scope of This Policy

This Policy describes the types of information we may collect from you or that you may provide when you visit the website www.creditunionbenefits.org and our practices for collecting, using, maintaining, protecting and disclosing that information.

This Policy applies to information we collect:

·      On this website;

·      In e-mail, text, and other electronic messages between you and our Services;

·      Through mobile and desktop applications you download as part of our Services or web applications that you access or use through our Services.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. By using the Services, you consent to the data practices prescribed in this Policy. We may periodically post changes to this Policy on this page by revising the date at the top of this Policy, and it is your responsibility to review this Policy, and we encourage you to visit this page often for any updates.

Limitations

Our Services is not intended for children under the age of 18 years old. No one under 18 may provide any personal information to or through our Services. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information through our Services. If we learn we have collected or received personal information from a child under 18 without verification of parental consent we will delete that information. If you believe we may have any information form or about a child under 178, please contact us at the addresses provided at the end of this Policy.

Our Services is intended for use by persons in the United States of America. If you are accessing our Services, you agree to be subject to the laws of the United States of America and your information will be handled in accordance with such laws. This website is not built to comply with the laws of any other country of nations. If you do not agree to have your information handled in accordance with US laws, you must not use our Services.

Information You Provide to Us

We collect information you provide to us, including but not limited to when you register for an account, complete a transaction, link an external account to the Services, sign up to receive our email updates, fill out a form, or when you communicate with us. The types of information we may collect include your name, phone number, email address, username, password, government-issued identification numbers and/or copies of government-issued identification cards, services or products requested, and any other information you choose to provide.

Information We Collect Automatically from our Services

When you use our Services, we automatically collect information about you as follows:

• Transaction Information. We collect information in connection with each transaction you engage in via the Services, including transaction time, amount of transaction, counterparties to each transaction (if any), and other transaction details.

• Log Information: We collect standard server logs in connection with your use of our Services, including the type of browser you use, access times, pages viewed, IP address, and the web page you visited before navigating to, or after navigation away from, our Services.

• Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.

• Location Information: With your permission, we collect precise location from your mobile device in connection with your use of our mobile app. We may also derive your approximate location from your IP address.

• Information Collected by Tracking Technologies:
  We may use various technologies to collect information in connection with your use of our Services. The technologies we use include the following:

  • Cookies, which are small files that are sent to your computer or mobile device when you visit a website. Cookies allow our Services to recognize your browser or device and track your usage each time you visit. You can usually decline or remove cookies through your browser or device, but doing so may interfere with your use of Services;

  • Web Beacons. Pages of our Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

  • Mobile device identifiers, which are unique identifiers established by your mobile device operating system that we collect from our mobile apps. These identifiers are used for similar purposes as cookies;

  • Local storage, which stores data locally in your browser, including user preferences; and

  • Pixel tags, which are small blocks of code often used in connection with cookies. Pixel tags (or web beacons) may be placed on our websites and emails, and allow us to track website usage, including to determine when emails have been opened and acted upon.

Information From Other Sources

We collect information from other companies and associate that with the information we collect about you. For example, in connection with your creation of an account, we may collect information about you from identity verification services, including your prior addresses and names. Also, if you use your credentials from a third-party social media service to log into your Services account, we may collect information from that service, such as your name and other account information, in accordance with the authorization procedures determined by that service. 

Security

Credit Union Benefits LLC takes reasonable measures designed to protect the information we collect from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. In particular, we implement reasonable security practices and procedures designed to protect the confidentiality and security of this information in accordance with, and prohibit disclosure other than as permitted by, this Policy. 

Transfer of Information to the U.S. and Other Countries

Credit Union Benefits LLC is based in the United States and the information we collect is governed by U.S. law. By accessing or using our Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law. 

Our use of Personal Information

We may use your information to: 

·       To fulfill any other purpose for which you provide it.

• Provide, maintain, and improve the Services;

• Process transactions and send notices about your transactions;

·       To fulfill any other purpose for which you provide it.

• To notify you about the changes to the Services and any other products or services we offer or provide

• Resolve disputes, troubleshoot problems, and provide customer service;

• Prevent and investigate violations of our terms and conditions and protect the rights and property of Credit Union Benefits LLC and others;

• Measure, analyze, and monitor trends, activities, and usage of the Services;

• Personalize the Services, including by delivering targeted content or advertisements;

• Send you targeted marketing, and promotional offers we think will be of interest to you;

• Verify your identity; and

• Carry out any other purpose described to you at the time the information was collected.

Our use of Other Information

The information we collect automatically may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our Services according to your individual interests.

• Speed up your searches.

• Recognize you when you return to our Services.

Sharing of Personal Information

We may share information about you as follows:

• With service providers that perform services on our behalf, including identity verification services, fraud prevention services, and email marketing services;

• With other companies as permitted by law, including our contractors, service providers and other third parties, and for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations, or report to credit bureaus.

  • For any other purpose disclosed by us when you provide the information

  • To comply with an applicable law or regulation, or in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process;

  • To protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability;

  • To protect the rights, property, and safety of Credit Union Benefits LLC or others;

  • In connection with a proposed or actual sale, merger, transfer, reorganization, equity swap, refinancing or exchange of all or a portion of Credit Union Benefits LLC assets to another company; and

  • With your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.

• With our subsidiaries and affiliates.

• We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

• As ordered by any Governmental Authority or quasi-governmental authority, upon receipt of a legal order, subpoena or other legal process.

• To enforce or apply our terms of use.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Credit Union Benefits LLC, our affiliates and subsidiaries, our customers, or others.

• We may also include your information in the leads that are sold to fulfillment agencies in order to complete and deliver requested products and services. We do not sell your information to third parties, but only to fulfillment companies and agents that we work with to deliver requested products and services.

Social Sharing Features 

The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features. By associating an account managed by a third party with your Credit Union Benefits LLC account and authorizing Credit Union Benefits LLC to have access to this information, you agree that Credit Union Benefits LLC may collect, store, and use this information in accordance with this Policy. 

Zoom and other Third-Party Services

Based on data you give us, we will facilitate the use of Zoom or other video conferencing or telecommunication services to communicate with a customer, and respond to requests for support. The categories of data we obtain are used to deliver our services and provide a better experience for you. Please see Zoom’s privacy policy for details pertaining to this service and other privacy policy of the service providers as applicable. We do not fetch or store your personal Zoom meeting information or credentials. Credit Union Benefits LLC uses an access token to communicate with your account. When you deauthorize Credit Union Benefits LLC from your Zoom account, your token and related data is deleted. By associating an account managed by a third party with your Credit Union Benefits LLC account and authorizing Credit Union Benefits LLC to have access to this information, you agree that Credit Union Benefits LLC may collect, store, and use this information in accordance with this Policy. 

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services and other websites and online services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Credit Union Benefits LLC and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites or online services, and better understand your online activity. You may be able to opt out of having third parties use your web browsing information for behavioral advertising purposes, by visiting www.aboutads.info/choices. You may also be able to opt out of having third parties use information collected through apps for behavioral advertising purposes by visiting your mobile device operating system settings. 

Account Information

You may access and update your account profile information by logging into your account via our Services. When you close your account, we may retain certain information as required by law or for our legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Promotional Communications

You may opt out of receiving promotional communications from Credit Union Benefits LLC by following the instructions in those messages. Please note that if you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations. 

Location Information

If you initially consent to the collection of precise location information by Credit Union Benefits LLC via our mobile app, you should be able to subsequently stop this collection through your device operating system settings or by removing our mobile app from your device. You understand and agree that disabling location information may limit the Services available to you.

Cookies and Local Storage

Most web browsers are set to accept cookies and local storage by default. If you prefer, you can usually choose to set your browser to remove browser cookies or clear local storage. Please note that if you choose to remove or reject these technologies, this could affect the availability and functionality of our Services. 

Mobile Push Notifications/Alerts.

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You should be able to stop receiving these messages by changing the notification settings on your mobile device.

Tracking Technologies

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

·      Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

·      Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data (if applicable). You can also always opt-out by logging into the Services and adjusting your user preferences in your account profile (if applicable).

·      Promotional Offers from the Company. If you do not wish to have your email address and other contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data by logging into the Services and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to the addresses provided at the end of this Policy. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Residents of certain states, such as California, Nevada, Colorado, Virginia, and Utah may have additional personal information rights and choices. See Your State Privacy Rights for more information.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Services and visiting your account profile page.

You may also send us an email at our address at the end of this Policy to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your State Privacy Rights

If you are a California, Nevada, Colorado, Virginia, or Utah resident, your state’s laws may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email or write to our Privacy Officer at the addresses provided at the end of this Policy.

Colorado, Virginia and Utah each provide their state residents with rights to:

·      Confirm whether we process their personal information.

·      Access and delete certain personal information.

·      Data portability.

·      Opt-out of personal data processing for targeted advertising and sales.

·      Colorado and Virginia also provide their state residents with rights to:

·      Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.

·      Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please contact our Privacy Officer at the addresses provided at the end of this Policy. To appeal a decision regarding a consumer rights request, you may write to our Privacy Officer within 45 days of any rejection. If our Privacy Officer still denies your request, you may submit a compliant to the Attorney General of the state where you reside.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to our Privacy Officer at the address found at the end of this Policy. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Additional Information for California Users

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to request access to or deletion of your personal information, and information about our data practices, as well as the right not to be discriminated against for exercising your privacy rights. To exercise such rights, please contact us at the address listed at the bottom of this Policy.

The CCPA sets forth certain obligations for businesses that “sell” personal information. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we may have sold the following categories of information about you in the past twelve months: Identifiers (such as name, address, email address, IP address, or device identifiers); internet or other network or device activity; geolocation information; professional or employment related data; potentially protected classifications (such as gender, nationality, and age); physical characteristics or description (such as when you voluntarily submit a photo through our Services); inferences related to the information identified.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services like message boards. The information you share in public areas may be viewed by any user of the Services.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

Contact Us

If you have any questions about this Policy, please contact us at Info@creditunionbenefits.org or send written correspondence to Credit Union Benefits LLC Privacy Department 3616 Kirkwood Highway, Suite A #1176 Wilmington DE 19808